Privacy Policy
This Privacy Policy describes how Divigent, Inc ("Divigent," "we," "us," or "our") collects, uses, discloses, and protects personal information in connection with the Divigent Protocol, the website at divigent.ai, the Divigent SDK, and related services (collectively, the "Services"). By using the Services, you acknowledge that your personal information will be processed as described in this Policy.
01Scope
This Policy applies to personal information we collect through the Services. It does not apply to personal information collected by third parties whose products or services may be referenced from or integrated with the Services, including without limitation operators of decentralized finance venues (such as Aave V3 and Morpho Prime), wallet providers, RPC providers, oracle providers, stablecoin issuers, blockchain network operators, or analytics providers. The privacy practices of those third parties are governed by their own privacy policies.
You acknowledge that public blockchain networks, including the Base network, are inherently transparent. Any wallet address, transaction, or other on-chain activity is publicly visible and is not within our control.
02Information We Collect
Information you provide directly
We collect personal information that you provide to us, such as:
- Contact information (such as name, email address, and company name) when you contact us, request early access, subscribe to updates, or otherwise correspond with us;
- Identifying information you provide as part of any partner, integration, or institutional onboarding process;
- Feedback, support requests, or other communications you submit to us.
Information collected automatically
When you use the Services, we and our service providers may automatically collect certain information, including:
- On-chain information such as wallet addresses that interact with the Divigent Protocol, transaction hashes, deposit and withdrawal amounts, and timestamps. This information is publicly available on the blockchain and is not generated by us;
- Device and usage information such as IP address, browser type and version, operating system, referring URL, pages visited, time spent, and approximate location derived from IP address;
- Cookies and similar technologies as described below.
Information from third parties
We may receive information about you from third parties, including analytics providers, blockchain analytics providers, anti-fraud and sanctions screening providers, marketing partners, and publicly available sources.
Wallet addresses and personal information
A wallet address by itself is generally pseudonymous. However, in certain jurisdictions and circumstances, a wallet address may be considered personal information when it can be associated with an identifiable individual. We treat wallet addresses as personal information where required by applicable law.
03How We Use Information
We use personal information for the following purposes:
- To provide and operate the Services, including to make the Divigent Protocol, SDK, and website available, to enable interactions with the Protocol, and to maintain the integrity of the system;
- To communicate with you, including to respond to inquiries, provide updates, send transactional and operational notices, and where you have opted in, to send marketing communications;
- To analyze and improve the Services, including to understand usage patterns, develop new features, and improve performance;
- To detect, prevent, and address fraud, abuse, security risks, and technical issues, including by performing sanctions and anti-money laundering screening of wallet addresses where appropriate;
- To comply with legal obligations and enforce our Terms, including to respond to lawful requests from public authorities and to protect our rights, property, and safety, and the rights, property, and safety of others;
- For other purposes with your consent or as otherwise permitted by applicable law.
04Legal Bases for Processing (EEA, UK, and Switzerland)
If you are located in the European Economic Area, the United Kingdom, or Switzerland, we process your personal information on the following legal bases:
- Performance of a contract, where processing is necessary to provide the Services to you;
- Legitimate interests, where processing is necessary for our legitimate interests in operating, securing, and improving the Services, provided those interests are not overridden by your rights and interests;
- Legal obligation, where processing is necessary to comply with a legal obligation, including sanctions and anti-money laundering compliance;
- Consent, where you have given consent (which you may withdraw at any time).
05How We Share Information
We do not sell your personal information. We may share personal information in the following circumstances:
| Recipient | Purpose |
|---|---|
| Service providers | Hosting, infrastructure, analytics, customer support, communications, security, and compliance services, subject to contractual confidentiality and data protection obligations. |
| Compliance and screening providers | Sanctions screening, anti-money laundering compliance, and fraud prevention. |
| Professional advisers | Legal, accounting, audit, and similar professional advisers, where reasonably necessary. |
| Authorities | Governmental, regulatory, or law enforcement authorities, where required by applicable law, subpoena, court order, or other legal process, or where reasonably necessary to protect our rights or those of others. |
| Corporate transactions | In connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our business or assets. |
| Affiliates | Within the Divigent group of companies for the purposes described in this Policy. |
| With your consent | Any other recipient with your direction or consent. |
We may also disclose aggregated or de-identified information that cannot reasonably be used to identify you for any purpose.
06Cookies and Similar Technologies
The Divigent website uses cookies and similar technologies to operate the site, remember your preferences, analyze traffic, and (where applicable) support marketing. Categories of cookies we may use include:
- Strictly necessary cookies, required to operate the site;
- Analytics cookies, which help us understand how visitors use the site;
- Functional cookies, which remember your preferences;
- Marketing cookies, where applicable and subject to consent.
You can control cookies through your browser settings and, where required, through the cookie consent banner displayed on the website. Disabling certain cookies may affect the functionality of the Services.
07Data Retention
We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to provide the Services, to comply with legal, accounting, or reporting obligations, to resolve disputes, and to enforce our agreements. Retention periods depend on the type of information and the context in which it was collected. On-chain data is recorded on a public blockchain and cannot be modified or deleted by us.
08Your Rights
EEA, UK, and Switzerland
Subject to applicable law and to certain exceptions, you may have the right to:
- Access the personal information we hold about you;
- Request correction of inaccurate or incomplete personal information;
- Request deletion of personal information;
- Object to or restrict certain processing;
- Request portability of personal information you have provided to us;
- Withdraw consent where processing is based on consent (without affecting the lawfulness of prior processing);
- Lodge a complaint with a supervisory authority in your country of residence or place of work.
California
If you are a California resident, you may have the right under the California Consumer Privacy Act (as amended by the California Privacy Rights Act) to know what personal information we collect, use, and disclose; to request deletion of personal information; to correct inaccurate personal information; to opt out of any sale or sharing of personal information (we do not sell personal information); and to be free from discrimination for exercising your rights.
Exercising your rights
To exercise any rights, please contact us at hello@divigent.ai. We may need to verify your identity before responding to your request. We will respond within the timeframes required by applicable law.
Please note that we cannot modify, delete, or otherwise control any information recorded on a public blockchain network, and rights of erasure or rectification will not extend to such information.
09International Data Transfers
We may process and store personal information in countries other than the country in which the information was originally collected, including the United States. Where we transfer personal information from the EEA, UK, or Switzerland to a country that has not been deemed to provide an adequate level of data protection, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, or other lawful transfer mechanisms.
10Security
We implement reasonable administrative, technical, and physical safeguards designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. No security program is perfect, and no method of transmission or storage is fully secure. You are solely responsible for safeguarding your wallet, your private keys, and your seed phrases.
11Children's Privacy
The Services are not directed to children under the age of eighteen (18), and we do not knowingly collect personal information from children. If we learn that we have collected personal information from a child, we will delete it as required by law. If you believe a child has provided us with personal information, please contact us at hello@divigent.ai.
12Third-Party Links and Services
The Services may contain links to or integrations with third-party websites, applications, and services. We are not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party services you use.
13Changes to This Policy
We may update this Policy from time to time. The "Last Updated" date above indicates when this Policy was last revised. Material changes will be communicated through the Services or, where appropriate, by other means. Your continued use of the Services after the effective date of any revised Policy constitutes your acceptance of the revised Policy.
14Contact
If you have any questions about this Policy or our privacy practices, or if you wish to exercise any of your rights, please contact us at:
Divigent, Inc
Attn: Privacy
Wilmington, Delaware, United States
Email: hello@divigent.ai